Full Breakdown
Gatekeepers Under Scrutiny: GI-TOC Report on Money-Laundering in Western Balkans
6/19/2026, 2:11:04 AM
Core Findings
On 18 June 2026 the Global Initiative Against Transnational Organized Crime (GI-TOC) published *Licence to Launder: Professional Money-Laundering Enablers in the Western Balkans*. Drawing on 89 interviews and legal-risk analysis in Albania, Bosnia-Herzegovina, Kosovo, Montenegro, North Macedonia and Serbia, the study labels lawyers, notaries, accountants, auditors and real-estate brokers as “professional enablers” who certify transactions without sufficient due-diligence, creating a veneer of legitimacy for illicit funds via real-estate deals, shell companies and falsified documents.
Background
All six jurisdictions have aligned AML legislation with EU and FATF standards, but the report finds fragmented supervision, limited inter-agency coordination and weak enforcement. Professional associations often lack authority to inspect members, and professional secrecy is frequently invoked to shield questionable transactions.
Data Spotlight
Montenegro’s notaries processed 19,857 property sales worth €1.6 billion in 2024 yet filed only two suspicious reports. North Macedonia legalises over 600 illegal constructions annually, a key conduit for illicit funds. Across the region, real-estate deals dominate laundering, with undervalued or inflated contracts, rapid related-party resales and notarized loans lacking clear funding. Offshore structures, cross-border corporate arrangements and cryptocurrency also obscure ownership.
Official Responses
The report urges risk-based supervision of designated non-financial professions, improved beneficial-ownership data and stronger regulator-financial-intelligence cooperation. The European Union, cited in the analysis, calls for stronger rule of law, anti-corruption measures and enhanced AML enforcement within the Western Balkans’ EU integration.
Criticism
Critics say notaries, brokers and accountants routinely formalize undervalued property sales, fictitious loans and inflated invoices, creating a façade for illicit funds. Fragmented oversight and limited scrutiny of cash-intensive transactions let organized-crime groups and politically exposed persons exploit professional channels. Prosecutions remain rare because of uneven supervisory capacity and limited ownership data.
Verbatim Quotes
- “We will first make them disappear, then transfer them to Hong Kong or somewhere else.” — Italian accountant, interviewee
- “Notaries often facilitate rapid title transfers, inflated property valuations and sales to off-shore linked buyers,” — GI-TOC report
- “In Kosovo, the report states, “professional enablers form tight inter-professional linkages servicing both organized crime groups and politically exposed persons.” — GI-TOC report
- “Further, the legalisation of illegal constructions,“averaging more than 600 buildings annually” in North Macedonia, functions as “a main channel for integrating illicit funds”.” — GI-TOC report
Conflicting Reports & Gaps
North Macedonia has the region’s most advanced notarial framework, yet suspicious reports from notaries rarely lead to investigations. Montenegro, by contrast, records high property-sale volumes but only two suspicious reports. The report also highlights few prosecutions of professional enablers, indicating a data gap on enforcement outcomes.
What’s Next
GI-TOC recommends clearer limits on professional secrecy, mandatory background checks for notaries and accountants, standardized reporting templates and feedback loops between financial-intelligence units and professionals. Implementing these measures is presented as essential for the Western Balkans to move beyond formal AML compliance toward demonstrable reductions in illicit-finance flows.
